On August 4, 2025, the NFPA EPS-AAA Technical Committee submitted Committee Input No. 25-NFPA 111-2025 — a proposal to create a new Annex D in NFPA 111 titled "Preventative Maintenance and Repair Considerations for SEPSS." The proposed annex addresses something the standard has never formally touched: what happens when your emergency power system gets old. Batteries degrade. Fuel systems corrode. Generators accumulate thousands of hours. Components reach end-of-life. The committee wants formal guidance in the standard on managing that aging process.
This is not enforceable code yet. It is a proposed annex — advisory, not mandatory. But it signals exactly where NFPA’s thinking is heading, and it will shape how AHJs and surveyors evaluate aging systems. Facilities running EPSS equipment that is 15, 20, or 25+ years old need to pay attention.
What the EPS-AAA Committee
Actually Proposed
Committee Input No. 25-NFPA 111-2025 is a Global Input — meaning it proposes an entirely new section rather than modifying existing language. The input requests creation of a new Annex D with the title "Preventative Maintenance and Repair Considerations for SEPSS" (Stationary Emergency Power Supply Systems).
The proposal text is direct: as SEPSS systems age, components degrade due to wear and environmental factors, increasing the risk of system malfunction. The annex would outline the importance of routine inspections, testing, and servicing of key components — batteries, generators, and fuel systems — and would address strategic maintenance and component replacement as methods to extend system life while maintaining NFPA 111 compliance.
Why NFPA 111 and Not NFPA 110?
The committee input was filed under NFPA 111 (Stored Electrical Energy Emergency and Standby Power Systems), not NFPA 110 (Emergency and Standby Power Systems). But do not let that distinction lull you into thinking this does not apply to your diesel genset. The same EPS-AAA Technical Committee oversees both standards, and the same committee input package (CI-25) also includes cross-references that update NFPA 111’s references to NFPA 110 from the 2025 edition to the 2028 edition. The standards move together.
More importantly, the aging problem described in the proposed annex — component degradation, battery failure, fuel system corrosion, increased malfunction risk — is identical whether the system is a UPS battery bank under NFPA 111 or a diesel generator under NFPA 110. If this guidance takes hold in NFPA 111, expect parallel language to follow in NFPA 110. That is how NFPA standards development works: one standard moves, the other follows.
Translation for facilities managers: This annex is filed under NFPA 111, but the concepts apply to every piece of emergency power equipment in your building. If NFPA is formalizing guidance on aging stored-energy systems, the same logic is coming for aging generators, ATS units, and fuel systems under NFPA 110. Plan accordingly.
What This Means for Facilities
Running Aging Equipment
Right now, NFPA 110 and 111 tell you what to test, how often to test it, and what records to keep. They do not tell you when a piece of equipment is too old to be reliable. They do not provide guidance on component lifecycle planning. They do not address the reality that a 25-year-old generator running on original fuel injectors is a different risk profile than a 5-year-old unit.
The proposed Annex D starts to close that gap. Even as advisory (non-mandatory) guidance, it creates a framework that AHJs, accreditation surveyors, and insurance carriers can point to when evaluating whether a facility is taking aging equipment seriously.
The Components That
Age Out First
The proposed annex specifically calls out batteries, generators, and fuel systems as the key components requiring aging-related maintenance attention. Based on field experience and manufacturer guidance, here is what actually degrades and when facilities should be paying attention.
The fuel problem is worse than most facilities realize. We consistently find degraded fuel as a contributing factor in generator failures during actual emergencies. A generator can start and run fine on a 30-minute monthly test and still fail at hour 6 of a real outage because the fuel filtration system cannot handle the volume of contaminants that get stirred up during extended operation. The proposed annex’s focus on fuel system aging is warranted.
How to Get Ahead of This
Before It Becomes Enforceable
The proposed Annex D is advisory. It is not in the standard yet. But the committee statement makes it clear that NFPA is looking for guidance on “installation and performance requirements that can help facilitate the awareness of condition of maintenance to ensure reliability.” That language tells you where this is going.
Here is what facilities should be doing now — not because the annex requires it, but because the annex is codifying what good practice already looks like.
- 01Inventory your EPSS equipment with install dates and hours. Every generator, ATS, UPS, battery bank, and fuel system component should have a documented age and condition status. If you do not know when your generator was installed, find the nameplate or contact the manufacturer with the serial number. You cannot manage aging equipment you have not inventoried.
- 02Create a component lifecycle plan. Map out the expected service life of each major component against its current age. Batteries, fuel injectors, coolant hoses, belts, turbocharger bearings, alternator bearings, control panel components — each has a service life window. Document where each component falls in that window.
- 03Get a fuel quality test. If your fuel has not been tested in the past 12 months, test it now. Test for water content, microbial contamination, particulate count, and oxidation stability. This is a low-cost action ($200–$500) that can prevent a high-cost failure.
- 04Budget for it. Use the proposed Annex D as supporting documentation in your next capital funding request. "NFPA’s EPS-AAA Technical Committee is developing formal guidance on aging emergency power systems" is a concrete, citable fact that strengthens a budget narrative. Attach the committee input document to the request.
- 05Schedule a condition assessment for equipment over 15 years old. Not a routine PM visit — a comprehensive evaluation of the system’s remaining useful life, component condition, and replacement priorities. This is the kind of assessment that the proposed annex is pointing toward as standard practice.
Aging EPSS Readiness Checklist
Use this checklist to assess your facility’s readiness for the direction NFPA standards are heading on aging emergency power systems.
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Equipment Inventory
All EPSS equipment has documented install dates, serial numbers, and cumulative runtime hours. -
Battery Assessment
Starting batteries have been load-tested (not just voltage-checked) within the past 6 months. Replacement date is documented if batteries are within 12 months of expected end-of-life. -
Fuel Quality
Fuel has been tested for water, microbial contamination, and particulate count within the past 12 months. Test results are on file. -
Component Lifecycle Plan
A documented plan exists mapping major components against expected service life and scheduled replacement windows. -
Capital Planning
If any EPSS equipment is over 15 years old, a formal condition assessment has been completed and a replacement/major-overhaul budget line exists in the capital plan. -
Documentation
Equipment age and condition status is documented in a format that can be produced during a survey or inspection.
Aging System Assessment
Our compliance gap report evaluates your entire EPSS against current and emerging NFPA requirements — including component age, condition, and lifecycle planning. Know where you stand before the standard catches up.
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